Mayflower District Court
#bob78711new-v-orangebear22
This is the start of #bob78711new-v-orangebear22 channel.
clerkFlow Bot2025-08-11 06:34 p.m.
clerkFlow pinned a message to this channel.2026-01-18 03:01 p.m.
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Chambers of Chief Judge Kezzera
Xerxy 2025-08-11 06:34 p.m.
emergency assignment @Kezzera
bob.gov 2025-08-11 06:43 p.m.@Kezzera Plaintiff is seeking a TRO application forthcoming
bob.gov
Kezzera 2025-08-11 07:16 p.m.
file on website @bob.gov
krm used /add
clerkFlow Bot2025-08-11 07:20 p.m. @krm has added @meowiitten to the case channel.
Case Modified
meowiitten 2025-08-11 07:23 p.m.@Kezzera Do you want a brief or
meowiitten 2025-08-11 07:23 p.m.
I don’t know how to respond to that motion because it cites no authorities
meowiitten 2025-08-11 07:23 p.m.
And just merely states what happened
meowiitten 2025-08-11 07:23 p.m.
Without presenting argument
meowiitten 2025-08-11 07:24 p.m.
He’s not entitled to any due process here
meowiitten 2025-08-11 07:24 p.m.
I wouldn’t even put this under due process clause analysis
meowiitten 2025-08-11 07:24 p.m.
This is Article V analysis
meowiitten 2025-08-11 07:24 p.m.
(And analogous US Const. Article II case law)
Kezzera 2025-08-11 07:25 p.m.
sorry, you are appearing for who?
meowiitten 2025-08-11 07:25 p.m.
State
meowiitten 2025-08-11 07:25 p.m.
Mr bear
Kezzera 2025-08-11 07:25 p.m.
okay
Kezzera 2025-08-11 07:25 p.m.
well i haven't got to this yet
Kezzera 2025-08-11 07:25 p.m.
would you be willing to wait for a brief moment on my instructions
Kezzera 2025-08-11 07:26 p.m.
i assume you have the complaint and the TRO papers?
Kezzerai assume you have the complaint and the TRO papers?
meowiitten 2025-08-11 07:26 p.m.
Oh no there hasn’t even been a complaint filed
meowiitten 2025-08-11 07:26 p.m.
Oh right
meowiitten 2025-08-11 07:27 p.m.
Oh my mistake
meowiitten 2025-08-11 07:27 p.m.
Yes there has
meowiitten 2025-08-11 07:27 p.m.
I see it now
meowiitten 2025-08-11 07:27 p.m.
I only read the TRO application
meowiitten 2025-08-11 07:27 p.m.
Give me a moment
meowiitten 2025-08-11 07:28 p.m.@Kezzera We can proceed to some kind of hearing on the TRO but the Defendant intends to move for summary judgment pretty early on
Kezzera 2025-08-11 07:37 p.m.
let's do oral
Kezzeralet's do oral
meowiitten 2025-08-11 07:42 p.m.
Pause but sure
Kezzera 2025-08-11 07:42 p.m.
oral hearing
meowiitten 2025-08-11 07:42 p.m.
Can we do it soon because we have a press conference at 9
Kezzera 2025-08-11 07:42 p.m.
to elaborate
Kezzera 2025-08-11 07:43 p.m.
finding out what's available
Kezzera 2025-08-11 07:44 p.m.
i can book us in for 8pm est tomorrow
Kezzera 2025-08-11 07:44 p.m.@meowiitten @bob.gov
meowiitten 2025-08-11 07:45 p.m.
Ok
Kezzerai can book us in for 8pm est tomorrow
meowiitten 2025-08-11 07:46 p.m.
Also please add effortlessbrit
Kezzera 2025-08-11 07:48 p.m.
will he enter an appearance?
Kezzerawill he enter an appearance?
meowiitten 2025-08-11 07:48 p.m.
Yeah
Kezzera 2025-08-11 07:48 p.m.
he'll be added if he does
meowiitten 2025-08-11 07:49 p.m.@Kezzera Would you like me to file my motion for summary judgment as well because if you find that the TRO isn't possible under the extensive legal precedent we will argue then you will essentially be establishing a prima facie case in our favor
Kezzera 2025-08-11 07:50 p.m.
it would be convenient
Kezzera 2025-08-11 07:52 p.m.
Case number changed
FROM: CV-386-25
TO: CV-390-25
Reason: Duplicate case number
FROM: CV-386-25
TO: CV-390-25
Reason: Duplicate case number
Kezzera pinned a message to this channel.2026-01-18 03:01 p.m.
Kezzera 2025-08-11 07:52 p.m.
Kezzera pinned a message to this channel.2026-01-18 03:01 p.m.
Kezzera 2025-08-11 07:53 p.m.@meowiitten enter your appearance by today
Kezzera 2025-08-11 07:53 p.m.
brit must likewise do the same
Kezzera 2025-08-11 07:53 p.m.
he's been added to the case on the website
UserMessage could not be loaded.
meowiitten 2025-08-11 07:57 p.m.
Kezzerai can book us in for 8pm est tomorrow
bob.gov 2025-08-11 08:40 p.m.
this is an urgent matter your honor
bob.gov 2025-08-11 08:40 p.m.
I would prefer tonight if possible
bob.gov 2025-08-11 08:40 p.m.
I have already been striped of my stuff in PAW
bob.gov 2025-08-11 08:50 p.m.@Kezzera please add my attorney @Arthur
bob.gov 2025-08-11 08:50 p.m.
I was told you would allow them to argue pro hace vice
krm used /add
clerkFlow Bot2025-08-11 08:53 p.m. @krm has added @Arthur to the case channel.
Case Modified
meowiittenOh no there hasn’t even been a complaint filed
Arthur 2025-08-11 08:56 p.m.
There is, it's attached on the website
ArthurThere is, it's attached on the website
meowiitten 2025-08-11 08:56 p.m.
Yep
meowiitten 2025-08-11 08:56 p.m.
The Honorable Notableants
meowiitten 2025-08-11 08:56 p.m.
Or Brenda
meowiittenOr Brenda
Arthur 2025-08-11 09:09 p.m.
?
Kezzera 2025-08-11 09:32 p.m.
a complaint is attached, see the website
Kezzera 2025-08-11 09:33 p.m.@Arthur file a notice of appearance
Kezzera 2025-08-11 09:34 p.m.
we'll receive it on the website
Kezzera 2025-08-11 09:46 p.m.
MINUTE ORDER: IT IS ORDERED that a hearing on Plaintiff's Application for a Temporary Restraining Order be set for 8:00PM EST, at Courtroom 2, Lander City Civil Courthouse. DivineCrime, Esq. is to appear for Plaintiff, and Sadoimpacto, Esq. is to appear for Defendant.(edited)
Kezzera 2025-08-11 09:47 p.m.@Arthur @meowiitten
bob.gov 2025-08-11 10:04 p.m.
for the record, "I love to violate peoples rights" and "I am a political persecutor" - orangebear22 https://www.youtube.com/watch?v=HaboN4rRjpM
meowiitten 2025-08-12 12:29 a.m.MEMORANDUM OF LAW IN SUPPORT OF DEFENDANT’S MOTION FOR SUMMARY JUDGMENT
@bob.gov @Kezzera
meowiitten 2025-08-12 12:29 a.m.
Sorry for the horrid writing I just got back from Ocala and I'm exhausted
meowiitten 2025-08-12 12:30 a.m.
ChatGPT-5 Pro was bustling away
Kezzera used /add
clerkFlow Bot2025-08-12 01:21 a.m. @Kezzera has added @Brit to the case channel.
Case Modified
meowiittenChatGPT-5 Pro was bustling away
Kezzera 2025-08-12 01:22 a.m.
sorry?
meowiitten 2025-08-12 01:25 a.m.
"It should be obvious that no one has a 'right' to a security clearance." Department of the Navy v. Egan , 484 U.S. 518, 528 (1988)
meowiitten 2025-08-12 01:25 a.m.
Kezzera 2025-08-12 01:26 a.m.
okay well
Kezzera 2025-08-12 01:26 a.m.
i'm gonna read your papers
Kezzera 2025-08-12 01:26 a.m.
and i will note your comment about gpt-5
meowiitten 2025-08-12 01:27 a.m.
Please go ahead sir
meowiitten"It should be obvious that no one has a 'right' to a security clearance." Department of the Navy v. Egan , 484 U.S. 518, 528 (1988)
meowiitten 2025-08-12 01:45 a.m.
I'll leave this for tomorrow as well
meowiitten 2025-08-12 01:45 a.m. 
meowiitten 2025-08-12 01:46 a.m. 
KezzeraMINUTE ORDER: IT IS ORDERED that a hearing on Plaintiff's Application for a Temporary Restraining Order be set for 8:00PM EST, at Courtroom 2, Lander City Civil Courthouse. DivineC...(edited)
Arthur 2025-08-12 07:55 a.m.
I cannot VC
Brit 2025-08-12 11:52 a.m.
1
We'd like to make our arguments in VC but would have no issue with Plaintiff responding verbally in-game
1
BritWe'd like to make our arguments in VC but would have no issue with Plaintiff responding verbally in-game
meowiitten 2025-08-12 02:10 p.m.
I won’t be able to see it so you’ll have to screen share
meowiittenI won’t be able to see it so you’ll have to screen share
Brit 2025-08-12 02:20 p.m.
That works fine for me
ArthurI cannot VC
Kezzera 2025-08-12 02:53 p.m.
I can consider submissions in-game
meowiitten 2025-08-12 07:39 p.m.@Kezzera Are we still on
Brit 2025-08-12 07:45 p.m.
We're ready to go in game and VC if the Court is ready
Brit 2025-08-12 07:50 p.m.AlbertWellesley is one of the millions creating and exploring the endless possibilities of Roblox. Join AlbertWellesley on Roblox and explore together!a 
Brit 2025-08-12 07:50 p.m.
Not sure which server his honour had in mind
meowiittenKezzera 2025-08-12 07:54 p.m.
yea
BritNot sure which server his honour had in mind
Kezzera 2025-08-12 07:54 p.m.
051a-4e90
Brit 2025-08-12 07:54 p.m.
Joining now
meowiitten 2025-08-12 07:55 p.m.
Ok Brit will join in game I'll be in VC
Kezzera 2025-08-12 07:56 p.m.
kk
bob.gov 2025-08-12 07:56 p.m.
not sure where my lawyer is, I am joining though
Kezzera 2025-08-12 07:56 p.m.
okay
Kezzera 2025-08-12 07:56 p.m.@Arthur Please remember to join this server around 051a-4e90
Kezzera 2025-08-12 07:57 p.m.
i've also been told mpbs is running a bit late, they're looking at around a :20 start, so we'll start absolutely then
Kezzera 2025-08-12 07:57 p.m.
take the extra time to prepare
Kezzera 2025-08-12 07:57 p.m.
appearances in-game should be by :15
Kezzera 2025-08-12 07:58 p.m.
i appreciate counselors receiving this notice very late, i just got told this
Brit 2025-08-12 07:59 p.m. 
krabz 2025-08-12 08:05 p.m.
Is this case boring
krabz 2025-08-12 08:05 p.m.
is it worthy of a ping for event-announcements
krabz 2025-08-12 08:06 p.m.@Kezzera
krabzis it worthy of a ping for event-announcements
Brit 2025-08-12 08:06 p.m.
It's high profile
Brit 2025-08-12 08:06 p.m.
boring is subjective
krabzis it worthy of a ping for event-announcements
Kezzera 2025-08-12 08:07 p.m.
probably?
Kezzera 2025-08-12 08:07 p.m.
i gave luso discretion on pinging
bob.gov 2025-08-12 08:08 p.m.@Kezzera my lawyer has not responded to me so dont ping incase he does not show
Kezzera 2025-08-12 08:08 p.m.
i'll expect them to appear by :20 at the latest
Kezzera 2025-08-12 08:08 p.m.
otherwise i will discuss with you your options after
Kezzera 2025-08-12 09:34 p.m.
Judgment reserved. Expected decision by 8/15 at 8:00PM EST unless otherwise ordered.
bob.gov 2025-08-12 10:22 p.m.
Your honor, this is supplemental but the defendant continues to defame me publicly, so I don’t see how the government can claim that the memos arnt defaming me when they allude I am a threat to national security coupled with this.
bob.gov 2025-08-12 10:22 p.m.
Cc; @Kezzera
meowiitten 2025-08-12 10:27 p.m.
This is not a defamation lawsuit.
bob.gov 2025-08-15 09:24 p.m.@Kezzera Judgement delayed?
Kezzera 2025-08-16 05:39 a.m.
Delayed until August 17
Kezzera 2025-08-18 01:02 a.m.
Delayed until August 20
Kezzera 2025-08-18 01:03 a.m.
(point 3 requires deeper analysis)
Brit 2025-08-21 06:00 a.m.@Kezzera
UserMessage could not be loaded.
Kezzera 2025-08-21 08:50 a.m.
bob.gov 2025-08-22 01:08 a.m.@Kezzera it is now the 22nd your honor
meowiitten 2025-08-22 11:45 p.m.
I withdraw as counsel
Kezzera 2025-08-22 11:47 p.m.
I need a reason, on the record, for withdrawal then I will enter in an order(edited)
Kezzera 2025-08-22 11:48 p.m.@meowiitten
KezzeraI need a reason, on the record, for withdrawal then I will enter in an order(edited)
meowiitten 2025-08-22 11:48 p.m.
As I have been commissioned into active service, I ask leave of the court to withdraw as counsel for the Defendant
Kezzera 2025-08-22 11:49 p.m.
The reasons are heard and withdrawal is granted. Order entered withdrawing Sadoimpacto from this case. @Brit remains for the Defendant Orangebear22(edited)
Kezzera 2025-08-26 11:16 p.m.@bob.gov @Brit Decision is released
Kezzera 2025-08-26 11:16 p.m.
check website thanks
bob.gov 2025-08-27 12:31 a.m.
An appeal was submitted to the supreme court on the decision, I ask the court stay proceedings till they respond.
Kezzera 2025-08-27 09:03 a.m.
I will refuse stay and enter case management directions today
bob.govAn appeal was submitted to the supreme court on the decision, I ask the court stay proceedings till they respond.
𝘴𝘰𝘧𝘪𝘦 ♥ 2025-08-27 04:56 p.m.
The petition for extraordinary relief is denied. [trello](https://trello.com/c/RZGeSN8r/104-bob78711new-v-orangebear22)(edited)
Kezzera 2025-08-27 06:34 p.m.
Errata order entered. See website for change to TRO.(edited)
Kezzera 2025-08-30 02:10 p.m.@bob.gov @Brit
Directions
Parties are required to now submit the following (if any):
1. Initial disclosures of witnesses to call
2. Materials for Discovery
3. Pre-trial motions
A briefing schedule is required. Parties should now enter into discussions on what documents it intends to file and when. I will ask that preparations not exceed more than 9 days. When dates and materials to be submitted have been agreed upon, either party may give notice of the proposed briefing schedule and I will enter it. Accordingly, please disclose when parties intend to disclose the relevant materials, etc. so I can enter an order for the pre-trial schedule.
You must meet and confer before expressing your intention to file any motions at this stage. Any motion must be accompanied by a meet and confer statement. LR 7. Example of a MAC statement:
"I, (your name), for the (party), state that it has met and conferred with the opposing party meeting with (counsellor's name) on (date) discussing the following:
- list of your motions
The parties, after the meet-and-confer, has:
agreed/not agreed on the resolution of issues related to (name of motion)
[if agreed: and respectfully request this Court to incorporate and construe the motions aforementioned as resolved and not to expect parties to file said motions.
[if its with prejudice: Such motions will not be filed in the future.]
Dated: (date)
(signature and print name of one of the parties)"(edited)
Parties are required to now submit the following (if any):
1. Initial disclosures of witnesses to call
2. Materials for Discovery
3. Pre-trial motions
A briefing schedule is required. Parties should now enter into discussions on what documents it intends to file and when. I will ask that preparations not exceed more than 9 days. When dates and materials to be submitted have been agreed upon, either party may give notice of the proposed briefing schedule and I will enter it. Accordingly, please disclose when parties intend to disclose the relevant materials, etc. so I can enter an order for the pre-trial schedule.
You must meet and confer before expressing your intention to file any motions at this stage. Any motion must be accompanied by a meet and confer statement. LR 7. Example of a MAC statement:
"I, (your name), for the (party), state that it has met and conferred with the opposing party meeting with (counsellor's name) on (date) discussing the following:
- list of your motions
The parties, after the meet-and-confer, has:
agreed/not agreed on the resolution of issues related to (name of motion)
[if agreed: and respectfully request this Court to incorporate and construe the motions aforementioned as resolved and not to expect parties to file said motions.
[if its with prejudice: Such motions will not be filed in the future.]
Dated: (date)
(signature and print name of one of the parties)"(edited)
Kezzera 2025-08-30 02:32 p.m.
Relevant order will be entered today
Brit 2025-08-30 06:39 p.m.@Kezzera When can we expect a response to our SJ motion?
Kezzera 2025-08-31 08:32 a.m.
If you read my latest decision you would have seen what happened to it
Kezzera 2025-08-31 08:33 a.m.
The fact that you ask me that is extremely disappointing
Kezzera 2025-08-31 08:33 a.m.
Please read the case entry, which is pinned in this channel
Kezzera 2025-08-31 08:33 a.m.@Brit
Kezzera 2025-08-31 08:34 a.m.
in the future. I reserved the SJ motion. It's considered later(edited)
Kezzera 2025-08-31 08:35 a.m.
I did not find it appropriate for the Defendants to have filed that at this stage, and I rely on Defendant's submissions from last time that the SJ motion is also to be constructed as a response to the TRO motion(edited)
Kezzerain the future. I reserved the SJ motion. It's considered later(edited)
Brit 2025-08-31 12:17 p.m.
I knoa you reserved it
Brit 2025-08-31 12:17 p.m.
know*
Brit 2025-08-31 12:18 p.m.
Would the Court be fine with a new SJ being submitted, providing the procedures outlined above are adhered to?
Kezzera 2025-08-31 01:52 p.m.
I wouldn't mind it if there's going to be a substantial difference from this SJ motion, which means you withdraw the one that's reserved for later
KezzeraI wouldn't mind it if there's going to be a substantial difference from this SJ motion, which means you withdraw the one that's reserved for later
Brit 2025-08-31 04:27 p.m.
I'll consider Defence's options and get back to the Court
Kezzera 2025-08-31 10:57 p.m.
Thanks
meowiitten 2025-09-03 06:58 p.m.@Kezzera Do you not expect us to move for summary judgment in this case I'm just a little confused
meowiitten 2025-09-03 06:58 p.m.
Or did you just disagree with us moving for summary judgment in opposition to the TRO
meowiitten 2025-09-03 06:58 p.m.
Our opposition to the TRO was verbal not in writing but the SJ brief could've also been applied liberally as part of our opposition
meowiitten 2025-09-03 06:59 p.m.
The SJ brief is its own thing
Kezzera 2025-09-03 08:30 p.m.
your arguments were from the SJ motion no?
Kezzera 2025-09-03 08:30 p.m.@meowiitten
meowiitten 2025-09-03 08:31 p.m.
Does it matter
Kezzera 2025-09-03 08:34 p.m.
well yeah since ill have to enter errata if the arguments made at the hearing and the sj motion were in fact to be considered separately
Kezzera 2025-09-03 08:35 p.m.
and not a situation where you filed the SJ motion in response to TRO
meowiittenOr did you just disagree with us moving for summary judgment in opposition to the TRO
Kezzera 2025-09-03 08:35 p.m.
because this would be inappropriate imo
Kezzera 2025-09-03 08:35 p.m.
you would instead just reply to the motion, and file SJ later after its been denied for instance
Kezzera 2025-09-03 08:36 p.m.
i wouldnt even begin to consider SJ without some discovery which i believe there's been a distinct lack of
Kezzera 2025-09-03 08:36 p.m.
jotp would have been proper
Kezzera 2025-09-03 08:37 p.m.
but i can construe those two liberally by just looking where were at w the case
Kezzerayou would instead just reply to the motion, and file SJ later after its been denied for instance
Kezzera 2025-09-03 08:38 p.m.
you can submit essentially the same arguments, modified to exclude the stuff replying to how it doesnt meet TRO
Kezzera 2025-09-03 08:38 p.m.
would appreciate a response today so i know if i need to enter errata and new directions so it makes sense
Kezzera 2025-09-03 08:39 p.m.@meowiitten
Kezzerai wouldnt even begin to consider SJ without some discovery which i believe there's been a distinct lack of
bob.gov 2025-09-03 11:22 p.m.
there are no facts in dispute if I am not mistaken your honor
Kezzerai wouldnt even begin to consider SJ without some discovery which i believe there's been a distinct lack of
meowiitten 2025-09-04 11:37 a.m.
:/
meowiitten 2025-09-04 11:38 a.m.
There’s cases that were resolved without summary judgment because there was no facts in dispute, like Bob said
meowiitten 2025-09-04 11:38 a.m.
Discovery is to arrange and clarify the facts through a record of evidence
meowiitten 2025-09-04 11:38 a.m.
All we would need is maybe a declaration attached to the motion to verify that all the facts are accurate
meowiitten 2025-09-04 11:39 a.m.
This case is ripe for either of us to move for summary judgment
meowiitten 2025-09-04 11:39 a.m.
Like if this was real life this case would not go to trial
meowiittenAll we would need is maybe a declaration attached to the motion to verify that all the facts are accurate
Kezzera 2025-09-05 01:02 p.m.
Where there's no dispute as to the facts then I will require a declaration from both sides about that
meowiittenDiscovery is to arrange and clarify the facts through a record of evidence
Kezzera 2025-09-05 01:03 p.m.
We went into this quite literally without clarifying this and you expect me to just assume there's none(edited)
Kezzera 2025-09-05 01:03 p.m.
Would be absurd
Kezzera 2025-09-05 01:03 p.m.
:/
Kezzera 2025-09-05 01:05 p.m.@meowiitten @bob.gov By sunday, file a declaration as to there being no dispute to the facts then I will consider it again
Kezzera 2025-09-05 01:06 p.m.
afterwards, my directions will change
Kezzerabob.gov 2025-09-05 01:09 p.m.
Just to clarify he will refile the motion and I will be permitted to respond to it?
Kezzera 2025-09-05 01:10 p.m.
He doesn't have to, I have it here
Kezzera 2025-09-05 01:11 p.m.
You can prepare your response to it now and just file it with us when I tell you to
meowiittenKezzera 2025-09-05 01:38 p.m.
well received, thank you
Kezzera 2025-09-05 01:41 p.m.@bob.gov
You are now instructed to file a response to the Motion for Summary Judgment (which contains a Memorandum of Law) within two days from the date of this message. No disputes as to facts are noted. I will consider the motion in two days and decide whether it should be granted or denied.
All documents will be entered onto the website.
You must file your response by:Sunday, September 7, 2025 at 1:40 p.m.
You are now instructed to file a response to the Motion for Summary Judgment (which contains a Memorandum of Law) within two days from the date of this message. No disputes as to facts are noted. I will consider the motion in two days and decide whether it should be granted or denied.
All documents will be entered onto the website.
You must file your response by:
bob.gov 2025-09-07 01:07 p.m.
bob.gov 2025-09-07 01:07 p.m.
Cc; @Kezzera
bob.govClick to see attachment.
meowiitten 2025-09-07 01:24 p.m.
1
I’ll just quickly respond:
1. The only reason MSPB review was required in Egan was because Congress required it by statute. Not required here. You are entitled to nothing with your SSC, and you are not entitled to know the reasons behind your revocation unless that is specifically in law.
2. For some reason the standard for a preliminary injunction is being applied to summary judgment, so I’m not going to comment on that.
3. Egan specifically says that revocation of a security clearance does not impute disloyalty or any other characteristic. The same could be said for removal of arrest powers and his commission since he is not entitled to either of those. But I’m not going to comment on this since stigma-plus is only invoked when (1) an actual charge is by a government actor in public, (2) the charge isfalse and defamatory , (3) there is a parity between the statement and the action against the person. No government actor made a statement about him aside from the memorandums (which do not speak by themselves). Also, even if he prevailed on liberty interest, the most the would get is a name-clearing hearing, not reinstatement.
4. Again, not going to comment because for some reason we are applying the PI/TRO standard to a summary judgment motion.
@Kezzera
1. The only reason MSPB review was required in Egan was because Congress required it by statute. Not required here. You are entitled to nothing with your SSC, and you are not entitled to know the reasons behind your revocation unless that is specifically in law.
2. For some reason the standard for a preliminary injunction is being applied to summary judgment, so I’m not going to comment on that.
3. Egan specifically says that revocation of a security clearance does not impute disloyalty or any other characteristic. The same could be said for removal of arrest powers and his commission since he is not entitled to either of those. But I’m not going to comment on this since stigma-plus is only invoked when (1) an actual charge is by a government actor in public, (2) the charge is
4. Again, not going to comment because for some reason we are applying the PI/TRO standard to a summary judgment motion.
1meowiittenI’ll just quickly respond: 1. The only reason MSPB review was required in Egan was because Congress required it by statute. Not required here. You are entitled to nothing with you...
bob.gov 2025-09-07 01:40 p.m.1
On point 1:
True that Egan involved MSPB review because Congress created it. But the constitutional floor of due process does not depend on statute. Cleveland Bd. of Educ. v. Loudermill, 470 U.S. 532, 541 (1985) - “[T]he right to due process ‘is conferred not by legislative grace, but by constitutional guarantee.’” Even if no statute requires a hearing, the Constitution does if a protected liberty or property interest is at stake. Also Mathews v. Eldridge, 424 U.S. 319 (1976) establishes that due process is not a question of statutory grace.
On point 2: You were claiming that no harm exists to the plaintiff in your motion so
On point 3: Egan said clearance revocation doesn’t necessarily impute disloyalty. But stigma can still arise from official action. Courts have repeatedly recognized stigma in government acts that implicitly brand an official unfit.
Codd v. Velger, 429 U.S. 624, 627 (1977) - stigma exists when the charge “might seriously damage his standing and associations in his community” or “impose on him a stigma or other disability that foreclosed his freedom to take advantage of other employment opportunities.” See also: Wisconsin v. Constantineau, 400 U.S. 433, 437 (1971), Owen v. City of Independence, 445 U.S. 622, 633 n.13 (1980),
The Governor’s memoranda are government action on the public record. That alone is enough to constitute publication. See Doe v. Dep’t of Justice, 753 F.2d 1092, 1113 (D.C. Cir. 1985) (agency memorandum revoking clearance constituted stigmatizing action when placed in personnel file).
and whilst the minimum is a hearing courts have reinstated officials where stigma-plus was proven and due process denied. See McGhee v. Draper, 639 F.2d 639, 643–44 (10th Cir. 1981).
True that Egan involved MSPB review because Congress created it. But the constitutional floor of due process does not depend on statute. Cleveland Bd. of Educ. v. Loudermill, 470 U.S. 532, 541 (1985) - “[T]he right to due process ‘is conferred not by legislative grace, but by constitutional guarantee.’” Even if no statute requires a hearing, the Constitution does if a protected liberty or property interest is at stake. Also Mathews v. Eldridge, 424 U.S. 319 (1976) establishes that due process is not a question of statutory grace.
On point 2: You were claiming that no harm exists to the plaintiff in your motion so
On point 3: Egan said clearance revocation doesn’t necessarily impute disloyalty. But stigma can still arise from official action. Courts have repeatedly recognized stigma in government acts that implicitly brand an official unfit.
Codd v. Velger, 429 U.S. 624, 627 (1977) - stigma exists when the charge “might seriously damage his standing and associations in his community” or “impose on him a stigma or other disability that foreclosed his freedom to take advantage of other employment opportunities.” See also: Wisconsin v. Constantineau, 400 U.S. 433, 437 (1971), Owen v. City of Independence, 445 U.S. 622, 633 n.13 (1980),
The Governor’s memoranda are government action on the public record. That alone is enough to constitute publication. See Doe v. Dep’t of Justice, 753 F.2d 1092, 1113 (D.C. Cir. 1985) (agency memorandum revoking clearance constituted stigmatizing action when placed in personnel file).
and whilst the minimum is a hearing courts have reinstated officials where stigma-plus was proven and due process denied. See McGhee v. Draper, 639 F.2d 639, 643–44 (10th Cir. 1981).
1bob.govOn point 1: True that Egan involved MSPB review because Congress created it. But the constitutional floor of due process does not depend on statute. Cleveland Bd. of Educ. v. Loud...
meowiitten 2025-09-07 02:04 p.m.1
1. A claim under Loudermill is quite different from a stigma-plus claim, because one involves a property interest and the other involves a liberty interest. Needless to say, even Loudermill didn't go as far as to confer an interest in everything simply because the government took something away from somebody. Interests are based on "existing rules or understandings that stem from an independent source, such as state law." State law does not vest a right to (1) a security clearance (and it never could), (2) law enforcement powers (in your capacity as an agent of the state, not as DA), and (3) your commission in the national guard (since the Adj. Gen. through the Governor has the ultimate discretion on whether someone can be commissioned).
3. No, stigma can't be implied from official action. There's no such thing as an implied stigma. Revoking a security clearance doesn't brand someone unfit, and even if it did, that's not for the Court to inquire into. Once again, liberty interest is only invoked where the charge isfalse and defamatory. The orders were all facially neutral and just took action without any additional commentary.
3. No, stigma can't be implied from official action. There's no such thing as an implied stigma. Revoking a security clearance doesn't brand someone unfit, and even if it did, that's not for the Court to inquire into. Once again, liberty interest is only invoked where the charge is
1meowiitten 2025-09-07 02:04 p.m.
Anyways I am satisfied with all of args
meowiitten 2025-09-07 02:04 p.m.@Kezzera Please rule on our stuff
bob.gov 2025-09-07 03:00 p.m.1
First, on Loudermill: counsel says that case only involved property interests, not liberty. But the Supreme Court has been very clear whether property or liberty, the principle is the same. Roth tells us due process attaches whenever state law gives someone an interest and the government takes it away. And Loudermill itself says due process is not “legislative grace,” it’s a constitutional guarantee. The Governor can’t strip away commissions, clearances, and law-enforcement powers that are essential to my office and say, “Well, because it’s discretionary, there’s no process.” That’s exactly backwards. When the government has the power to take away something that defines your ability to serve, that’s when the Constitution requires process most.
Second, on stigma: counsel says there’s no such thing as “implied stigma,” and only an express false charge would count. That’s not the law. Constantineau held that just posting a person’s name without any defamatory commentary was stigma enough when tied to government action. Owen v. City of Independence recognized that a termination itself carries stigma because it brands a public servant as unfit. And the D.C. Circuit in Doe v. DOJ said the very act of revoking a clearance can stigmatize because it signals unfitness and blocks future employment.
Second, on stigma: counsel says there’s no such thing as “implied stigma,” and only an express false charge would count. That’s not the law. Constantineau held that just posting a person’s name without any defamatory commentary was stigma enough when tied to government action. Owen v. City of Independence recognized that a termination itself carries stigma because it brands a public servant as unfit. And the D.C. Circuit in Doe v. DOJ said the very act of revoking a clearance can stigmatize because it signals unfitness and blocks future employment.
1meowiitten 2025-09-07 04:16 p.m.
Constantineau isn't really the accepted view anymore
bob.gov 2025-09-07 11:04 p.m.
any proof of that?
meowiitten 2025-09-07 11:35 p.m.Consider four different potential plaintiffs.
Yeah just read this https://lawreview.uchicago.edu/print-archive/stigma-plus-whom-evaluating-causation-multiple-actor-stigma-plus-claims
bob.gov 2025-09-07 11:53 p.m.
this is primarily acedemic and I am not just saying reputational harm is a due process violation, its change in legal status coupled with reputational harm
Kezzera 2025-09-09 10:28 a.m.
Will look to enter decision this week - thanks
Kezzera 2025-09-09 10:28 a.m.
No further arguments are necessary at this stage unless specifically requested by the Court
bob.gov 2025-09-12 12:30 a.m.@Kezzera I would like to make the court aware that the CA has prohibited them from revoking my law enforcement powers: https://drive.google.com/file/d/1xwPZs9PD0DwG9yMo-bOkzqPdkRl54uko/view
meowiitten 2025-09-12 12:36 a.m.
So then only two points left
bob.govKezzera 2025-09-12 01:32 a.m.
This doesn't affect you?
Kezzera 2025-09-12 01:32 a.m.
ah wait
Kezzera 2025-09-12 01:32 a.m.
it would
Kezzera 2025-09-12 01:33 a.m.
okay, it is noted
Kezzera 2025-09-12 01:33 a.m.
as to point 3 (PAW-CCSO Memo)?
Kezzera 2025-09-12 01:33 a.m.@bob.gov @meowiitten
Kezzeraas to point 3 (PAW-CCSO Memo)?
bob.gov 2025-09-12 01:37 a.m.
I bealeve its aplicability could be streched to MNG
bob.gov 2025-09-12 01:37 a.m.
sorry its late I cant spell
bob.gov 2025-09-12 01:37 a.m.
its applicable to MNG in my opinion as well
meowiitten 2025-09-12 01:38 a.m.
I would not go that far but yes to PAW
meowiitten 2025-09-12 01:38 a.m.
I mean we can just ask Krabz(edited)
meowiitten 2025-09-12 01:38 a.m.
Krabz
meowiitten 2025-09-12 01:38 a.m.@krabz
bob.gov 2025-09-12 01:38 a.m.
and as to my argument to due process as a constitutional requirement for SC not just statutory
meowiittenI mean we can just ask Krabz(edited)
bob.gov 2025-09-12 01:38 a.m.
fair
bob.govand as to my argument to due process as a constitutional requirement for SC not just statutory
meowiitten 2025-09-12 01:39 a.m.
No the SC thing is clearly like
meowiitten 2025-09-12 01:39 a.m.
You have no process due(edited)
meowiitten 2025-09-12 01:39 a.m.
Lets be real
meowiitten 2025-09-12 01:39 a.m.
The commission I can see a challenge
bob.gov 2025-09-12 01:40 a.m.
the 14th in plain text states: "nor deny to any person within its jurisdiction the equal protection of the laws."
bob.gov 2025-09-12 01:40 a.m.
the memmo very clearly targeted myself and others
bob.gov 2025-09-12 01:40 a.m.
with no evidence behind it
meowiitten 2025-09-12 01:41 a.m.
It doesn’t matter
meowiitten 2025-09-12 01:41 a.m.
Perkins Cole LLP was targeted by Trump and both the district and circuit court upheld the security clearance revocation
bob.gov 2025-09-12 01:41 a.m.
u gotta have somthing other than it does not matter to weigh against the 14th amendment
meowiitten 2025-09-12 01:41 a.m.
Like they were specifically named in the order
meowiittenPerkins Cole LLP was targeted by Trump and both the district and circuit court upheld the security clearance revocation
bob.gov 2025-09-12 01:41 a.m.
thats federal
bob.gov 2025-09-12 01:41 a.m.
we are a state
bob.gov 2025-09-12 01:42 a.m.
and they had due process
bob.gov 2025-09-12 01:42 a.m.
I dont
meowiitten 2025-09-12 01:42 a.m.
No he didn’t have due process
meowiitten 2025-09-12 01:42 a.m.
The president just revoked it by EO
meowiitten 2025-09-12 01:42 a.m.
This was about the whole thing with Trump revoking people who associated with jack smith
bob.gov 2025-09-12 01:42 a.m.
they can appeal
meowiitten 2025-09-12 01:43 a.m.
Okay let’s not be ridiculous
meowiitten 2025-09-12 01:43 a.m.
I said you can challenge the commission revocation
meowiitten 2025-09-12 01:44 a.m.
There is nothing you can do about the security clearance except going to brawladdie
meowiitten 2025-09-12 01:44 a.m.
Which I encourage you to do if you feel it is unjust
meowiittenThis was about the whole thing with Trump revoking people who associated with jack smith
meowiitten 2025-09-12 01:45 a.m.
To add to this in another EO he was naming people specifically like Letitia James and revoking their shit
meowiitten 2025-09-12 01:45 a.m.
No there was no process beforehand
meowiitten 2025-09-12 01:45 a.m.MEMORANDUM FOR THE HEADS OF EXECUTIVE DEPARTMENTS AND AGENCIES SUBJECT: Rescinding Security Clearances and Access to Classified Information from 
meowiittenNo there was no process beforehand
bob.gov 2025-09-12 01:46 a.m.
process does not always need to be beforehand
bob.gov 2025-09-12 01:46 a.m.
egan appealed afterwords
meowiitten 2025-09-12 01:46 a.m.
I mean yeah and his case was dismissed for non-justiciability(edited)
meowiitten 2025-09-12 01:47 a.m.
They specifically said there was no right to a security clearance
bob.gov 2025-09-12 01:47 a.m.
yes but not no right to process
Kezzera 2025-09-12 01:47 a.m.
STOP
Kezzera 2025-09-12 01:47 a.m.
STOP
Kezzera 2025-09-12 01:47 a.m.
STOPPPP
Kezzera 2025-09-12 01:47 a.m.STOP
bob.gov 2025-09-12 01:47 a.m.
Apologies your honor
Kezzera 2025-09-12 01:47 a.m.
BOTH OF YOU
Kezzera 2025-09-12 01:47 a.m.
PLEASE
Kezzera 2025-09-12 01:47 a.m.
STOP WITH THE BACK AND FORTH HERE
meowiitten 2025-09-12 01:48 a.m.@Kezzera I mean quite honestly there’s one thing you need to do which is limit this case to a singular issue that being his commission but sure I will stop
Kezzera 2025-09-12 01:48 a.m.
Yes we can literally resolve that issue now, just none of the back and forth here please
Kezzera 2025-09-12 01:48 a.m.
especially where I do not need to be privy to it (since it seems to be a debate between you two specifically)
meowiitten 2025-09-12 01:48 a.m.@krabz krabzzzzzzuhhh
meowiitten 2025-09-12 01:49 a.m.@krabz
Kezzera 2025-09-12 01:49 a.m.
let me look at what was said
Kezzera 2025-09-12 01:50 a.m.
look, point 3 will likely be rendered a non-issue since bob will very much be affected by this
Kezzera 2025-09-12 01:51 a.m.
intervention from central authority
Kezzera 2025-09-12 01:51 a.m.
point 1 ive made my opinion clear, the security clearance, so i invited stronger positions as to it
Kezzera 2025-09-12 01:51 a.m.
or a very different position from last time(edited)
Kezzera 2025-09-12 01:52 a.m.
point 2 i've left that to challenge and that's what i think would likely be addressed
Kezzera 2025-09-12 01:52 a.m.
in SJ
bob.gov 2025-09-12 01:52 a.m.
May I submit a brief on point 3 at a later point
Kezzera 2025-09-12 01:53 a.m.
even if you are likely to be restored law enforcement powers?
bob.gov 2025-09-12 01:53 a.m.
Well its an obstruction of my law enforcement powers granted by CA
Kezzera 2025-09-12 01:54 a.m.
you said you had none
Kezzera 2025-09-12 01:54 a.m.
you were not a cop
bob.gov 2025-09-12 01:54 a.m.
parking enforcement
bob.gov 2025-09-12 01:54 a.m.
its very loosly defined
bob.gov 2025-09-12 01:54 a.m.
but my positions in general
bob.gov 2025-09-12 01:54 a.m.
the EO states: "You shall ensure that all physical and digital access held by the named
individual to classified repositories, secure facilities, protected databases, internal
communications platforms, and intelligence systems is terminated immediately
upon receipt of this memorandum. You shall also take steps to secure, retrieve, and
account for any classified or sensitive materials, whether physical or electronic, that
are currently in his possession or control, and to verify that no copies remain
accessible to him"
individual to classified repositories, secure facilities, protected databases, internal
communications platforms, and intelligence systems is terminated immediately
upon receipt of this memorandum. You shall also take steps to secure, retrieve, and
account for any classified or sensitive materials, whether physical or electronic, that
are currently in his possession or control, and to verify that no copies remain
accessible to him"
Kezzera 2025-09-12 01:54 a.m.
genuinely, what the fuck?
Kezzera 2025-09-12 01:54 a.m.
are we serious?
bob.gov 2025-09-12 01:55 a.m.
it clearly bans me from seeing the discord
bob.gov 2025-09-12 01:55 a.m.
of the depts I am employed by
Kezzera 2025-09-12 01:55 a.m.
that's point 1
meowiitten 2025-09-12 01:55 a.m.
Uh it would not ban you from seeing the discord as the person who issued the order(edited)
Kezzera 2025-09-12 01:55 a.m.
point 3 is your ccso-paw memo
bob.gov 2025-09-12 01:55 a.m.
"internal communications platforms,"
Kezzerathat's point 1
bob.gov 2025-09-12 01:55 a.m.
my b
bob.gov 2025-09-12 01:55 a.m.
its late guys
bob.gov 2025-09-12 01:55 a.m.
I finished writing an essay not 15 minutes ago
bob.gov 2025-09-12 01:56 a.m.
I ment point 1
bob.gov 2025-09-12 01:56 a.m.
on the brief
Kezzera 2025-09-12 01:56 a.m.
you're still free to submit stuff on it yes but i believe you've already responded
Kezzera 2025-09-12 01:56 a.m.
to all 3 points
Kezzera 2025-09-12 01:56 a.m.
the brief would have to be very short and supplementing only point 1
Kezzera 2025-09-12 01:57 a.m.
i would see no point if it adds no insight
Kezzera 2025-09-12 01:57 a.m.
and if its to throw a couple of cases around, just file an authorities list and a small summary for each cases
Kezzera 2025-09-12 01:58 a.m.
likewise, government responds with the same if they wish
meowiitten 2025-09-12 01:58 a.m.
I just don’t like that the security clearance challenge is essentially just asking for process for the sake of process
meowiitten 2025-09-12 01:58 a.m.
I am fine with the challenge to the commission, I welcome it
Kezzera 2025-09-12 02:00 a.m.
it's his choice which points he wishes to challenge unless we stop it - believe he's already made his responses and raised his challenges throughout
Kezzera 2025-09-12 02:00 a.m.
and anything further is purely supplemental
Kezzera 2025-09-12 02:00 a.m.
if you both want to discuss what you guys want to resolve now and still continue to challenge, do it privately and NOT HERE.
Kezzera 2025-09-12 02:00 a.m.
then you can come back to me
Kezzera 2025-09-12 02:00 a.m.
with what you want to proceed
meowiitten 2025-09-12 02:00 a.m.1
1meowiitten 2025-09-12 02:01 a.m.
This should be consulted
Kezzera 2025-09-12 02:01 a.m.
i'm more than happy to work around that
meowiittenKezzera 2025-09-12 02:01 a.m.
thanks, will note
Kezzera 2025-09-12 02:01 a.m.@bob.gov you can likewise do the same
Kezzeraif you both want to discuss what you guys want to resolve now and still continue to challenge, do it privately and NOT HERE.
Kezzera 2025-09-12 02:01 a.m.
but, just talk this out
meowiitten 2025-09-12 02:02 a.m.1
1Kezzera 2025-09-12 02:02 a.m.
don't do it here, i am not interested in making this really cluttered - my staff would appreciate it
meowiittenmeowiitten 2025-09-12 02:02 a.m.
DC Circuit opinion which is cited in this case
Kezzera 2025-09-12 02:02 a.m.
okay, thank you general
Kezzera 2025-09-12 02:02 a.m.
i appreciate that greatly
Kezzera 2025-09-17 02:21 p.m.@meowiitten @bob.gov @Brit
Summary judgment is granted in part and denied in part. See website for details.
Summary judgment is granted in part and denied in part. See website for details.
KezzeraKezzera 2025-09-17 02:21 p.m.
.
Kezzerameowiitten 2025-09-17 02:25 p.m.
I don't see it on there
Kezzera 2025-09-17 02:26 p.m.
should be now
Kezzera 2025-09-17 02:26 p.m.
labelled ORDER 9/17/25
meowiitten 2025-09-17 02:28 p.m.
There's a bit of a mistake he was not fired from PAW by us @Kezzera
meowiitten 2025-09-17 02:28 p.m.
And if he is challenging that, and he was fired (?), he is not suing the right person
meowiitten 2025-09-17 02:29 p.m.
He is also not suing the right person if he wants to remain in MNG
meowiitten 2025-09-17 02:29 p.m.
As orangebear only revoked his commission
Kezzera 2025-09-17 02:30 p.m.
General
Kezzera 2025-09-17 02:30 p.m.
I caution you strongly to reconsider your statements
meowiitten 2025-09-17 02:31 p.m.
I can assure you this is a traceability issue if he wants to remain in MNG and PAW
meowiitten 2025-09-17 02:31 p.m.
He's not suing the right person
Kezzera 2025-09-17 02:31 p.m.
This Court has, in its hands, a copy of all three directives/memorandums which plainly states this
Kezzera 2025-09-17 02:31 p.m. 
Kezzera 2025-09-17 02:31 p.m.
What is it then?
meowiitten 2025-09-17 02:31 p.m.
Well again, he's not suing the right person. That's all I said
meowiitten 2025-09-17 02:32 p.m.
This Court can't order the Governor to reinstate Bob to the Guard insofar as it pertains to his commission. So if he wants to remain in MNG, he needs to sue MNG as well
meowiitten 2025-09-17 02:32 p.m.
In a capacity below that of a commissioned officer
Kezzera 2025-09-17 02:32 p.m.
You have not read my order whatsoever
Kezzera 2025-09-17 02:32 p.m.
You need to read it
Kezzera 2025-09-17 02:32 p.m.
I addressed this
Kezzera 2025-09-17 02:33 p.m.
Please read it
Kezzera 2025-09-17 02:33 p.m.
If there's something wrong about it, you need to motion errata or vacating of my judgment on substantial errors
meowiitten 2025-09-17 02:33 p.m.
I did read it you said he needs due process to be fully discharged from the Guard (would not be done by the Governor) and PAW (again would also not be done by the Governor, and we didn't fire him from PAW, if he was fired from PAW?)
meowiitten 2025-09-17 02:34 p.m.
He needs to add MNG and PAW as defendants
Kezzera 2025-09-17 02:34 p.m.
Why wasn't this raised earlier then?
Kezzera 2025-09-17 02:34 p.m.
You should be aware of the facts surrounding Defendant's situation
meowiitten 2025-09-17 02:34 p.m.
This can be raised at any time
meowiitten 2025-09-17 02:35 p.m.
It's subject matter
meowiitten 2025-09-17 02:35 p.m.
It can be raised pre or post judgment
Kezzera 2025-09-17 02:35 p.m.
I express my deepest frustrations with you on this and I trust that you'll move for corrections as needed
Kezzera 2025-09-17 02:36 p.m.
because I will not take any blame for this, these were the representations made and I am not charged with hunting for this information beyond this court
KezzeraYou should be aware of the facts surrounding Defendant's situation
meowiitten 2025-09-17 02:36 p.m.
No I wasn't because the lawsuit rests largely on manufacturings and emotional grievances as is the nature of most lawsuits so we ignored that and focused on the material facts, that being the series of events and the plain text of the memorandums
meowiitten 2025-09-17 02:36 p.m.
If he claims he was fired from PAW that is not traceable to orangebear22 or the memorandums themselves
meowiitten 2025-09-17 02:36 p.m.
He was not to be fired from PAW
meowiitten 2025-09-17 02:36 p.m.
And I don't think he was
meowiitten 2025-09-17 02:37 p.m.
I deny any knowledge of that if he was
Kezzera 2025-09-17 02:37 p.m.
Okay
Kezzera 2025-09-17 02:37 p.m.
that's fine
Kezzera 2025-09-17 02:37 p.m.
We have summary judgment granted for the commission and the security clearance
Kezzera 2025-09-17 02:37 p.m.
the rest is still up for lively litigation
Kezzera 2025-09-17 02:37 p.m.
So changes can still be made
Kezzera 2025-09-17 02:38 p.m.
I will trust that Plaintiff be urged to request this court to include defendants, or otherwise clarify that issue
Kezzera 2025-09-17 02:38 p.m.
with regards to his dismissal
Kezzera 2025-09-17 02:38 p.m.
because I only had three papers and whatever he told me
Kezzera 2025-09-17 02:38 p.m.
and the same from you
Kezzera 2025-09-17 02:39 p.m.
We have not made much meaningful discovery but it was technically fine to proceed with SJ now
Kezzera 2025-09-17 02:39 p.m.
as we had some discovery
Kezzera 2025-09-17 02:39 p.m.
We proceed with more of that and eventual trial if necessary
Kezzera 2025-09-17 02:40 p.m.
The memorandums said this, this is the likely construction of it (the MNG one can not be more clearer about dismissal, the PAW one was quite obvious)(edited)
Kezzera 2025-09-17 02:41 p.m.
You can move to correct it, and submit your view on this, I'll invite it
Kezzera 2025-09-17 02:41 p.m.
and likewise bob will get the same opportunity
Kezzera 2025-09-17 02:41 p.m.@bob.gov @meowiitten
meowiitten 2025-09-17 02:52 p.m.
Nevertheless we got pretty much all we wanted
Kezzera 2025-09-17 04:48 p.m.
fair
bob.gov 2025-09-17 07:30 p.m.@Kezzera to clarify, the order ordered my firing, I seek injunction from that, I told the now director about the suit and he agreed to allow me to remain in the service until this is finalized, however my enforcement powers (which have now been returned thanks to the grace of CA) were gone.
bob.gov 2025-09-17 07:30 p.m.
Anyway I did not get to submit my thing in time
bob.gov 2025-09-17 07:30 p.m.
was busy with school
bob.gov 2025-09-17 07:30 p.m.
will the court allow a motion to reconsider down the line when I finalise it?
Kezzera 2025-09-17 09:55 p.m.
Motion to reconsider?
Kezzera 2025-09-17 10:45 p.m.
uh
Kezzera 2025-09-17 10:45 p.m.
it seems that the attorney general is gone..?
Kezzera 2025-09-17 10:45 p.m.@bob.gov
Kezzera 2025-09-17 10:45 p.m.@Brit
KezzeraMotion to reconsider?
bob.gov 2025-09-18 12:04 a.m.
yes
Kezzerait seems that the attorney general is gone..?
bob.gov 2025-09-18 12:04 a.m.
good ridence
Kezzera 2025-09-18 12:14 a.m.
False alarm
KezzeraFalse alarm
bob.gov 2025-09-18 01:19 a.m.
bob.gov 2025-09-18 01:20 a.m.
Kezzera 2025-09-18 01:53 a.m.
?????????????
Kezzera 2025-09-18 01:53 a.m.
What the fuck are you doing??
Kezzera 2025-09-18 01:53 a.m.@bob.gov
Brit 2025-09-18 10:16 a.m.@Kezzera We motion for sanctions
bob.gov 2025-09-18 12:29 p.m.
No one approved sanctions when Sado broke bar rules but now they want sanctions when I post a gif
Kezzera 2025-09-18 02:00 p.m.
That's hardly relevant here and is not my responsibility
Kezzera 2025-09-18 02:01 p.m.
You have rules to follow when you're in my court
BritKezzera 2025-09-18 02:01 p.m.
Written Motion
KezzeraWritten Motion
Brit 2025-09-18 02:17 p.m.
I'll write it up for this weekend Your Honour
Kezzera 2025-09-18 02:20 p.m.
Today
Kezzera 2025-09-18 02:20 p.m.@Brit
KezzeraBrit 2025-09-18 02:21 p.m.
I'm busy with Uni tonight and have to be up early tomorrow for a supervision
Kezzera 2025-09-18 03:28 p.m.
okay, tomorrow end of day BST @Brit
Kezzera 2025-09-18 03:28 p.m.
otherwise i'll deal with it accordingly
Kezzera 2025-09-18 03:29 p.m.
(im taking this as your intention to motion for sanc, so i won't do anything on my own)
Kezzera used /add
clerkFlow Bot2025-09-19 03:00 p.m. @Kezzera has added @meowiitten to the case channel.
Case Modified
bob.gov 2025-09-19 04:59 p.m.@Kezzera I am being persecuted for this suit
bob.gov 2025-09-19 05:00 p.m. 
Kezzera 2025-09-19 05:38 p.m.
We have been made aware of a warrant issued against you
Kezzera 2025-09-19 05:38 p.m.@bob.gov
Kezzera 2025-09-19 05:38 p.m.
You must not appear in Court personally
Kezzera 2025-09-19 05:38 p.m.
We will be adjourned indefinitely until we're back in session
Kezzera 2025-09-19 05:38 p.m.
Run
Kezzera 2025-09-19 08:35 p.m.
We're back
KezzeraWe're back
bob.gov 2025-09-20 01:31 p.m.
Yes after escaping to quanahassit I took a trip to Israel and got their blessing I am safe now
Kezzera 2025-09-20 11:59 p.m.
did you pray on the western wall
Kezzeradid you pray on the western wall
meowiitten 2025-09-21 01:31 a.m.
So what's left again? Firing from PAW (I guess moot?)
meowiitten 2025-09-21 01:32 a.m.
I was confused on the MNG point since you said yes his commission can be withdrawn but also that he can't be completely removed from MNG without some kind of process
meowiitten 2025-09-21 01:32 a.m.
His employment in MNG was contingent on his commission, from what I understand
meowiitten 2025-09-21 01:32 a.m.
So if he lost his commission he would be discharged
meowiitten 2025-09-21 01:32 a.m.
He was serving at the pleasure of the Governor, through the Adjutant General
Kezzeradid you pray on the western wall
bob.gov 2025-09-21 11:41 a.m.
Yes
meowiittenHis employment in MNG was contingent on his commission, from what I understand
bob.gov 2025-09-21 11:41 a.m.
No it was not?
bob.gov 2025-09-21 11:41 a.m.
I enlisted regularly
bob.gov 2025-09-21 11:42 a.m.
Went into jag
bob.gov 2025-09-21 11:42 a.m.
Transferred and became enlisted again
bob.gov 2025-09-21 11:42 a.m.
Then earned my commission
Kezzera 2025-09-21 04:38 p.m.
we'll likely have to enter further discovery then
Kezzera 2025-09-21 04:39 p.m.@meowiitten @bob.gov
Kezzera 2025-09-21 04:39 p.m.
i'll order that today
meowiitten 2025-09-22 05:22 p.m.
I move to recuse you @Kezzera since you have prejudged this matter in-chambers in re bob78711new-v-t4k3nw
meowiitten 2025-09-22 05:22 p.m.
I will have it in writing
meowiitten 2025-09-22 05:22 p.m.
Please appoint another district judge to review the motion
Kezzera 2025-09-22 05:23 p.m.
Consequentely as a result of that case I will have the remaining counselor take over
Kezzera 2025-09-22 05:24 p.m.
Attorney General for State Representation is hereby terminated.(edited)
Kezzera 2025-09-22 05:24 p.m.@Brit Remains and assumes counsel of record
Kezzera 2025-09-22 07:39 p.m.
This order stands.
Kezzera 2025-09-23 01:56 p.m.
Revisiting (including discovery order)
bob.gov 2025-09-24 01:13 p.m.@Kezzera do you have a copy of the ruling on the summary judgment
bob.gov 2025-09-24 01:14 p.m.
It was on the website so I can’t see it
Kezzera 2025-09-24 02:09 p.m.
yes, i'll post it here today
Kezzerayes, i'll post it here today
bob.gov 2025-09-24 07:39 p.m.
ty
bob.gov 2025-09-26 01:42 p.m.
Ty
UserMessage could not be loaded.
Deverus 2025-09-26 08:56 p.m.
Deverus 2025-09-26 08:56 p.m.
cc: @bob.gov @orange @k
UserMessage could not be loaded.
bob.gov 2025-09-26 08:56 p.m.
judicialFLOW Bot2025-09-26 09:36 p.m.Requester: @k
Party:Defense
Channel:bob78711new-v-orangebear22
A Magistrate Judge or higher may approve or deny below. 
Request ID: cbee960c38114674bf06719d8d6be01e Approve Deny
(edited)
Appearance Request
Party:
Channel:
A Magistrate Judge or higher may approve or deny below.
Status
Deverus used /add
clerkFlow Bot2025-09-26 09:55 p.m. @Deverus has added @k to the case channel.
Case Modified
Deverus 2025-09-26 09:55 p.m.@k I've added you manually (as i cannot accept using the above prompt) considering you're filling fmr. Attorney General sadoimpacto's spot in this case.
Keep in mind Albert may require you to provide other notice of appearance when he returns.
Keep in mind Albert may require you to provide other notice of appearance when he returns.
judicialFLOW Bot2025-09-27 10:49 a.m.@k appears for Defense (approved by @krm ).
judicialFLOW pinned a message to this channel.2026-01-18 03:01 p.m.
Kezzera 2025-09-30 07:35 a.m.
Appearance noted Xolaaz for Defendant
Kezzera 2025-10-08 03:41 a.m.@bob.gov Some time has passed since our last discussion about this case - confirm whether:
- you are in the National Guard
- you have obtained or been restored a commission and what grade
- whether your MPAW position has been restored
- you are in the National Guard
- you have obtained or been restored a commission and what grade
- whether your MPAW position has been restored
Kezzera 2025-10-08 03:44 a.m.
Similarly for @k - please confirm whether State intends to make any requests as to the summary judgment I handed down
Kezzera 2025-10-08 03:44 a.m.
because the former General has stated there should be, but has made no formal request pointing this out
Kezzera 2025-10-08 03:45 a.m.
and for @bob.gov and @k Whether we need to enter into discovery
Kezzera 2025-10-08 03:45 a.m.
I believe the last issue - the dismissals - were resolved by central authority intervention but I cannot find any explicit references to that intervention
Kezzera 2025-10-08 03:45 a.m.
One of you should be able to find that out
Kezzerabob.gov 2025-10-08 11:15 a.m.
I have not been reinstated back into MNG nor have I obtained a commission
Kezzera 2025-10-08 12:45 p.m.
why do you have the jag role then?
Kezzera 2025-10-08 12:46 p.m.@bob.gov
Kezzerawhy do you have the jag role then?
bob.gov 2025-10-08 01:33 p.m.
IDK
bob.gov 2025-10-08 01:33 p.m.
No one ever removed it
Kezzera 2025-10-08 03:27 p.m.
i swear it was
Kezzera 2025-10-08 03:27 p.m.
right
Kezzera 2025-10-08 03:27 p.m.
there - i fixed your roles(edited)
Kezzera 2025-10-11 01:17 a.m.@bob.gov you mentioned before about the directives being reversed
Kezzera 2025-10-11 01:17 a.m.
am i correct on that or?
Kezzera 2025-10-11 01:18 a.m.
this was when we had a brief discussion about mootness on the third point
Kezzerabob.gov 2025-10-11 12:23 p.m.
CA enjoined the revoking of any law enforcement status
bob.gov 2025-10-11 12:24 p.m.
but if I am being honest it would not hurt for the courts to uphold that
bob.gov 2025-10-11 12:24 p.m.
Additionally, if you will allow it, on security clearance, I'd like to provide a foundational peace of caselaw I feel I overlooked when drafting my filings
bob.gov 2025-10-11 12:25 p.m.
You can construe this as a motion to reconsdier since it was in summary judgement
Kezzera 2025-10-11 12:46 p.m.
ehhh
Kezzera 2025-10-11 12:46 p.m.
right well, you have to file that directly so
Kezzera 2025-10-11 12:47 p.m.
we have a trello card, let me just check if i can upload stuff to it this time
Kezzera 2025-10-11 12:47 p.m. Transitional Case
This case existed prior to courts.clarkcounty.site shutting down. This card has been created to keep a record of the case’s existence; however, it will not be updated with past, present, or future case information.
This case existed prior to courts.clarkcounty.site shutting down. This card has been created to keep a record of the case’s existence; however, it will not be updated with past, present, or future case information.
Labels
Civil, Transitional CaseKezzera 2025-10-11 12:50 p.m.
ok, works
Kezzera 2025-10-11 12:50 p.m.
use the /upload command and put in c7UcfTko for the card_short_id field
Kezzera 2025-10-11 12:50 p.m.
you then follow the instructions given to you
Kezzera 2025-10-11 12:50 p.m.
i'll know when you uploaded it
Kezzera 2025-10-11 12:50 p.m.
MTRs will have to be written as they are significant
bob.govbut if I am being honest it would not hurt for the courts to uphold that
Kezzera 2025-10-11 12:51 p.m.
i have no choice
Kezzera 2025-10-11 12:51 p.m.
i just need the copy of it again
Kezzera 2025-10-11 12:51 p.m.
if i get it, i'll enter it and remove issue 3 from consideration
Kezzeraif i get it, i'll enter it and remove issue 3 from consideration
bob.gov 2025-10-11 12:53 p.m.
its on the CA mandaates thing
bob.gov 2025-10-11 12:53 p.m.
I think
bob.gov 2025-10-11 12:53 p.m.
or ask krabz
bob.gov 2025-10-11 12:53 p.m.
it was issued from the registrars office
Kezzera 2025-10-11 12:55 p.m.
1s
Kezzera 2025-10-11 12:59 p.m.
well
Kezzera 2025-10-11 01:00 p.m.
issue 3 may still stand
Kezzera 2025-10-11 01:00 p.m.
unless state turns over nothing for this court to review
Kezzera 2025-10-11 01:00 p.m.
the prospective prohibition clause doesn't specifically drop your directive but anything like it on acc. of evidence - if i remember the state had mentioned something (at that time) that would support the directive(edited)
Kezzera 2025-10-11 01:01 p.m.
but we haven't even got to that point yet
Kezzera 2025-10-11 01:01 p.m.@k you have until tomorrow to respond back to me clarifying whether you intend to engage in discovery
Kezzera 2025-10-11 01:02 p.m.
for issue 3, which is the dismissal from the guard and (mpaw i think)
Kezzera 2025-10-11 01:02 p.m.
if you don't respond, i will take it as if you waived any opportunity to meaningfully respond (as you've had this whole time to) and make a finding that no evidence exists
Kezzera 2025-10-11 01:03 p.m.
and declare that issue 3 is dead, and allow plaintiff to be restored to the guard
Kezzera 2025-10-11 01:03 p.m.
and wherever else he was dismissed from
Kezzera 2025-10-11 01:03 p.m.
you can also respond back saying there is nothing
KezzeraKezzera 2025-10-11 01:04 p.m.Sunday, October 12, 2025 at 12:55 p.m.
4 months ago
(due date)
(due date)
Kezzera 2025-10-11 01:04 p.m.
i will not allow this to go on any longer than it needs to, i think i've let this go on for long enough
Kezzera 2025-10-11 01:05 p.m.
here's the [mandate](https://drive.google.com/file/d/1xwPZs9PD0DwG9yMo-bOkzqPdkRl54uko/view) for reference
Kezzera 2025-10-11 01:06 p.m.
and yes, any doj attorney who has been asked to appear may appear and let me know(edited)
Kezzera 2025-10-11 01:07 p.m.
for other doj attys: if i find out you were unauthorized or don't have any real knowledge of this situation i will disregard your response and terminate your appearance accordingly
Kezzeraand declare that issue 3 is dead, and allow plaintiff to be restored to the guard
bob.gov 2025-10-11 01:27 p.m.
Am I to return with commission?
bob.gov 2025-10-11 01:27 p.m.
because, if the court finds it proper, the argument could be made that the prohibition would extend to the arbitrary revocation of my commission
judicialFLOW Bot2025-10-11 01:47 p.m.@bob.gov please upload attachments for bob78711new v. orangebear22 now. You can send multiple messages. Type
Allowed types: application/pdf, image/jpeg, image/png, image/webp, text/plain
donejudicialFLOW Bot2025-10-11 01:47 p.m.@bob.gov accepted 1 file(s). (Total: 1/5)
judicialFLOW Bot2025-10-11 01:47 p.m.@bob.gov You can upload 4 more — or type
donebob.gov 2025-10-11 01:47 p.m.
done
UserMessage could not be loaded.
judicialFLOW Bot2025-10-11 01:47 p.m.
Uploaded 1/1 file(s).
bob.gov 2025-10-11 01:47 p.m.
it only lets me upload here
bob.govClick to see attachment.
bob.gov 2025-10-11 01:48 p.m.
Cc; @Kezzera
bob.govAm I to return with commission?
bob.gov 2025-10-11 01:48 p.m.
also bot burried this
bob.govAm I to return with commission?
Kezzera 2025-10-11 02:03 p.m.
i don't follow the question
bob.govalso bot burried this
Kezzera 2025-10-11 02:03 p.m.
got ur papers on the card, ty
Kezzerai don't follow the question
bob.gov 2025-10-11 02:15 p.m.
Am I to return to the guard as my former position or as an enlisted
Kezzera 2025-10-12 02:32 a.m.
enlisted unless your mtr is accepted and judgment revisited
Kezzeraenlisted unless your mtr is accepted and judgment revisited
bob.gov 2025-10-12 12:56 p.m.
I wrote it specifically for the security clearance but the principal can be applied to both
Kezzera 2025-10-12 04:29 p.m.
oh well that's different
KezzeraKezzera 2025-10-12 04:31 p.m.
Deadline missed
bob.govKezzera 2025-10-12 04:31 p.m.@k You should have also received this
bob.gov 2025-10-13 12:33 p.m.@Kezzera can we proceed
Kezzerabob.gov 2025-10-13 12:33 p.m.
Also can you pin this please
bob.gov 2025-10-13 12:35 p.m.
Also looking back now there was never a reply to the civil complaint either
Kezzera 2025-10-13 12:36 p.m.
oh yeah
Kezzera 2025-10-13 12:36 p.m.
wait, no
Kezzera 2025-10-13 12:37 p.m.
pretty sure there was one?
Kezzerapretty sure there was one?
bob.gov 2025-10-13 12:40 p.m.
I just scanned the entire thing
bob.gov 2025-10-13 12:41 p.m.
Only the MSJ
bob.gov 2025-10-13 12:41 p.m.
From what I saw
Kezzera 2025-10-13 04:48 p.m.
ah.. i see
bob.govAlso looking back now there was never a reply to the civil complaint either
k 2025-10-13 06:09 p.m.
Can you send me the screenshot of the civil service
kCan you send me the screenshot of the civil service
bob.gov 2025-10-13 06:15 p.m.
Not this BS again
bob.gov 2025-10-13 06:15 p.m.
It’s already been ruled https://discord.com/channels/1274202187911790632/1418133741846396999/1426684165050335375
bob.gov 2025-10-13 06:15 p.m.
That if someone appears they wave summons
k 2025-10-13 06:15 p.m.
We are in judge alberts court
k 2025-10-13 06:15 p.m.
Not alex j cabots
bob.gov 2025-10-13 06:16 p.m.
It’s caselaw now bud
k 2025-10-13 06:16 p.m.
are you..
bob.gov 2025-10-13 06:16 p.m.
Your predecessor appeared
k 2025-10-13 06:16 p.m.
Please someone kill me
bob.govYour predecessor appeared
bob.gov 2025-10-13 06:17 p.m.
Kezzera 2025-10-14 05:16 a.m.
yeah we're pretty far in to deal with personal jurisdiction issues
Kezzera 2025-10-14 05:16 a.m.
not that it was really even an issue in the first place
Kezzera 2025-10-14 05:16 a.m.
you've missed deadlines i've set(edited)
bob.govKezzera 2025-10-14 05:17 a.m.
including this
k 2025-10-14 05:01 p.m.
This is a very weak MTR
bob.gov 2025-10-16 05:32 p.m.@Kezzera where are we with this
bob.gov 2025-10-16 05:32 p.m.
Also with bob78711new-v-t4k3nw (I have no perms to speak there)
bob.govAlso with bob78711new-v-t4k3nw (I have no perms to speak there)
Kezzera 2025-10-16 08:50 p.m.
Don't request for action in other cases here
bob.govKezzera 2025-10-16 08:51 p.m.
Deadlines are past
Kezzera 2025-10-16 08:51 p.m.
so will write judgment and hand these down
Kezzera 2025-10-16 08:51 p.m.
as to issue 3 and MTR
bob.gov 2025-10-19 01:05 a.m.@Kezzera when can we expect judgement?
bob.gov 2025-11-06 10:50 p.m.@Kezzera
judicialFLOW Bot2025-11-07 01:43 p.m.@Kezzera please upload attachments for bob78711new v. orangebear22 now. You can send multiple messages. Type
Allowed types: application/pdf, image/jpeg, image/png, image/webp, text/plain
donejudicialFLOW Bot2025-11-07 01:43 p.m.@Kezzera accepted 1 file(s). (Total: 1/5)
judicialFLOW Bot2025-11-07 01:43 p.m.@Kezzera You can upload 4 more — or type
doneKezzera 2025-11-07 01:43 p.m.
done
UserMessage could not be loaded.
judicialFLOW Bot2025-11-07 01:43 p.m.
Uploaded 1/1 file(s).
Kezzera 2025-11-07 01:43 p.m.
Judgment now available
KezzeraJudgment now available
bob.gov 2025-11-07 05:46 p.m.
Ty
clerkFlow Bot2025-12-01 07:21 a.m. Permissions have been synced to
Channel Permissions Synced
Volume XIIIkrabz used /transcript
clerkFlow Bot2026-01-18 02:19 p.m.
Creating transcript..
clerkFlow Bot2026-01-18 02:19 p.m.
https://discord.com/channels/1274202187911790632/1329678726383927409/1462526855751139499 Successfully created transcript.
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